Cc@Toby Ellis, Esq. @huddy. @SledCrab
Link: no link (just a NOA)

https://drive.google.com/file/d/1QaaPDz0yiWdOwyURRRti3qTJ5F59EDjj/view?usp=sharing
https://drive.google.com/file/d/1A9dIWH3245VkdxOi5wygsxn3j4HZapAt/view?usp=sharing
https://drive.google.com/file/d/1C0G3NUobJHTrvt9auV1oVXbsMTLFQytN/view?usp=sharing
Cc@Toby Ellis, Esq. @Fish
Courtesy link: https://drive.google.com/file/d/1tR_7UHgY6aPLH9s-Ce6gJ8zbZ8QJURyH/view?usp=share_link
The defense's statement misstates the standard used in Iqbal and Twombly. A complaint must plead both factual allegations and a plausible legal claim. For such, 8(a)(2) of the Mayflower R. Civ. P. requires "a short and plain statement of the claim showing that the pleader is entitled to relief".
Mayflower R. Civ. P. 11(b) explicitly requires that a pleading must "state a cause of action" and contain "a short and plain statement of the ultimate facts showing that the pleader is entitled to relief"
Our complain satisfies both rules in addition to Iqbal and Twombly. It clearly identifies the causes of action and supports each with detailed factual allegations. If these facts are taken as true, the court will be allowed to reasonably infer the defendant's liability. For that, our pleading meets the standard of plausibility, defendant's assertion is incorrect and cannot support dismissal.

Chambers of Chancery, Lord ShahVolume XI